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Data Retention Schedule

How long ChefSphere keeps each category of personal and operational data, the legal basis for each retention, and the mechanism that deletes or anonymises the data at the end of the window.

v1.9.0 · Effective: June 18, 2026 · 9 minute read

Contents

  • 1. How to read this schedule
  • 2. Account and identity data
  • 3. Content created by users
  • 4. Health and wellness data (Art. 9 GDPR)
  • 5. AI usage data
  • 6. Payment, billing, tax
  • 7. Marketplace operational records
  • 8. Trust-and-safety, moderation, abuse reports
  • 9. Device, technical, and security data
  • 10. Communications
  • 11. Backups
  • 12. Legal holds
  • 13. Verification
  • 14. Anonymisation vs deletion
  • 15. Changes
  • 16. Contact

This Data Retention Schedule lists how long ChefSphere OÜ ("ChefSphere") keeps each category of personal and operational data, on what legal basis, and through what mechanism the data is removed at the end of its retention window. It is published under Art. 5(1)(e) GDPR (storage limitation) and under the transparency obligations of Arts. 12–14 GDPR. It supplements the Privacy Policy §7 — where a retention window is described in prose — and supersedes any conflicting statement made in a prior policy version for new processing from the effective date.

1. How to read this schedule

ColumnMeaning
DatasetThe personal or operational data held, described at a granularity meaningful to a data subject.
Legal basis for the retentionThe statutory or contractual rule that authorises retention for the stated period.
RetentionThe active retention window on production systems.
Deletion mechanismHow data is removed: scheduled job, policy-driven purge, manual deletion, anonymisation, or contractually-mandated destruction by a processor.
ExceptionAny rule that extends or truncates the default retention (for example a legal hold, an open investigation, a user-initiated account deletion).

All retention windows are maximums. Data is deleted as soon as it is no longer needed for the original purpose, even before the maximum is reached.

2. Account and identity data

DatasetLegal basisRetentionDeletion mechanismException
Email, password hash (bcrypt), display name, age band, language, timezone, verification statusArt. 6(1)(b) GDPR (contract)Life of the account + 12 months after closureNightly deletion job for closed-account records past the grace windowRecords subject to an open legal claim are placed on legal hold and excluded from the job until release
Two-factor authentication settings (TOTP secret, recovery codes hash)Art. 6(1)(b) + 6(1)(f) (security)Life of the accountRemoved synchronously on 2FA disable—
Authentication identifiers from Google, Facebook, Apple sign-inArt. 6(1)(b)Life of the account + 12 months after closureNightly deletion job—
Active and expired device / session recordsArt. 6(1)(f) (security)90 days rollingDaily truncation job—
Identity-verification results (seller / author KYC)Art. 6(1)(c) (AML / KYC)5 years after the last marketplace transactionScheduled purge post-AML retentionRaw ID document is not stored — only pass/fail and a reference ID held by Stripe

3. Content created by users

DatasetLegal basisRetentionDeletion mechanismException
Posts, recipes, comments, reactions, follow graphArt. 6(1)(b) (contract)Life of the account + standard operational purge window after deletion (≤ 30 days for production; ≤ 90 days for index purge)User-initiated delete + scheduled post-account-closure purgeContent under an open DSA Art. 16 notice is preserved for the notice-and-action cycle
Direct messages, group messagesArt. 6(1)(b)Life of the conversation; on account closure, messages visible to the other participant persist until they delete their side, then removed on both sidesPer-message soft-delete then hard-delete 30 days after both sides soft-deleted—
Ebook reader data (bookmarks, highlights, reading progress)Art. 6(1)(b)Life of the accountUser-initiated delete—
Community prices, reviews, ratingsArt. 6(1)(b)Life of the account; anonymised aggregates may persist after the account is closed to preserve marketplace integrityPer-item delete + anonymisation of underlying aggregatesReviews tied to a completed transaction persist with the transaction record

4. Health and wellness data (Art. 9 GDPR)

DatasetLegal basisRetentionDeletion mechanismException
Nutrition targets, intake, water, sleep, workout entriesExplicit consent — Art. 9(2)(a)Life of the feature being enabled; deleted within 30 days of withdrawal of consentWithdraw-consent action triggers purge job immediatelyBackups roll off within 30 days
AI health-feature context (profile dietary preferences used for ranking recipes)Explicit consent — Art. 9(2)(a)Same as aboveSame as above—

5. AI usage data

DatasetLegal basisRetentionDeletion mechanismException
AI Chef conversation history (user side)Art. 6(1)(b)Life of the account; user-initiated clear button purges immediatelyUser-initiated clear—
AI prompts and outputs sent to providerArt. 6(1)(b) + contractual no-training clause with providerProvider-side: up to 30 days for safety review then deleted, per provider contract; ChefSphere side mirrors the user chat historyProvider's retention policy enforces on their sideAbuse-investigation may extend up to 180 days
AI generation artefacts for Art. 50(4) deepfake labellingArt. 6(1)(c) (AI Act compliance)24 monthsScheduled purge job—

6. Payment, billing, tax

DatasetLegal basisRetentionDeletion mechanismException
Invoices, receipts, chargebacks, refunds, tax records, order historyArt. 6(1)(c) — Estonian Accounting Act (Raamatupidamise seadus §12)10 years from end of financial yearAnnual rollover job; anonymised after retention if operationally needed—
Payment-method references (last 4, brand, billing country)Art. 6(1)(b) / 6(1)(c)Life of the account; removed from active table on account closure, kept on invoice for 10 yearsScheduled purge—
DAC7 seller reportsArt. 6(1)(c) — Directive (EU) 2021/51410 yearsScheduled purge—
VAT / OSS remittance recordsArt. 6(1)(c) — Council Directive 2006/112/EC as implemented in EE10 yearsScheduled purge—

7. Marketplace operational records

DatasetLegal basisRetentionDeletion mechanismException
Order records, rental records, shipping trackingArt. 6(1)(b)10 years (invoice obligation) — then anonymisedAnnual rolloverRecords under an open dispute are retained until resolution
Listing photos, videos, descriptionsArt. 6(1)(b)Life of the listing + 30 days post-removal for audit evidenceScheduled purge—
GPSR traceability records (technical documentation, instructions, safety warnings per Art. 9(2) GPSR)Art. 6(1)(c) — Reg. (EU) 2023/98810 years from date the product was placed on the marketScheduled purge—
Marketplace chat, meet-up evidence (photos, timestamps)Art. 6(1)(b) + 6(1)(f)3 years default; up to 10 years where a GPSR incident or dispute is openScheduled purgeOpen-dispute exception

8. Trust-and-safety, moderation, abuse reports

DatasetLegal basisRetentionDeletion mechanismException
Moderation decisions, DSA Statements of ReasonsArt. 6(1)(c) — Reg. (EU) 2022/2065 Arts. 17 + 24(5)3 years (default); 5 years for serious cases; DSA Transparency Database submissions retained indefinitely in aggregateScheduled purge; aggregate summaries retained for the annual report—
Abuse reports received at [email protected]Art. 6(1)(c) + 6(1)(f)2 yearsScheduled purgeOpen-case exception
DMCA / CDSM takedown records, counter-noticesArt. 6(1)(c) — 17 U.S.C. §512 + Reg. (EU) 2022/20653 years; repeat-infringer register kept for the life of the policy windowScheduled purge—
Suspensions under Art. 23 DSAArt. 6(1)(c)2 yearsScheduled purge—

9. Device, technical, and security data

DatasetLegal basisRetentionDeletion mechanismException
Access logs (web, API, mobile)Art. 6(1)(f) — security90 days on hot storage, 365 days on cold storageTiered-storage retention policyIncident-response extension up to 7 years if a breach is under investigation
Web Application Firewall and DDoS logsArt. 6(1)(f)90 days rollingWAF provider purge—
Crash reports, stack traces, performance tracesArt. 6(1)(f)90 daysProvider purge—
Security audit trail (privileged operations by ChefSphere staff)Art. 6(1)(c) + 6(1)(f)7 yearsImmutable append-only store; scheduled archival—
Two-factor authentication attempts, password resets, sign-in eventsArt. 6(1)(f)365 daysScheduled purge—

10. Communications

DatasetLegal basisRetentionDeletion mechanismException
Support tickets and email threads with usersArt. 6(1)(b)3 years from closureScheduled purgeOpen-claim exception
Legal and authority correspondenceArt. 6(1)(c)7 years (Estonian administrative-law default)Immutable archival with scheduled purge—
Marketing consent records and historyArt. 6(1)(c) — evidential purpose3 years after consent withdrawalScheduled purge—
Transactional emails (billing, security, password resets)Art. 6(1)(b)2 yearsProvider purge—

11. Backups

  • Production databases are backed up using a combination of continuous write-ahead-log streaming and periodic snapshots.
  • Rolling backup retention is 30 days. A record that is deleted in production is overwritten in backups within 30 days.
  • Long-term archival snapshots (where taken for disaster-recovery) are encrypted with a separate key and retained for a maximum of 180 days before deletion; no long-term personal-data retention sits in backups only.

12. Legal holds

If ChefSphere is served with a preservation order, a court subpoena, an MLAT, or becomes aware of a reasonably foreseeable litigation, the dataset covered by the hold is excluded from the deletion jobs in this schedule until the hold is released. Holds are administered by the Law Enforcement Response Team and documented in the audit trail at §9.

13. Verification

A data subject can request confirmation that retention windows have been applied to their data, through the mechanisms in the Privacy Policy §9 (in-app Privacy Controls, authenticated API, or email to [email protected]). The DSAR pipeline returns a copy of personal data that is still held together with the retention window that applies to each category.

14. Anonymisation vs deletion

Where a dataset is removed through anonymisation rather than hard deletion, the result is irreversible: the anonymised record can no longer be linked back to an identifiable natural person without additional information we do not hold and will not obtain. Anonymisation is used primarily for analytics signals, marketplace aggregates, and research datasets. Personal data is always deleted (not anonymised) unless anonymisation is expressly preferable for the purpose.

15. Changes

We update this schedule when a retention rule changes — whether because of law, operational learning, a new feature, or the end of a legacy processing activity. Changes take effect at the effective date shown in the header; prior versions are available on request at [email protected].

16. Contact

  • Privacy / data-subject requests: [email protected]
  • DPO: [email protected]
  • Legal holds and authority requests: [email protected]

ChefSphere OÜ

Estonian registry code: 17470129 · Tartu Maakohtu registriosakond

c/o E-Residency Hub OÜ, Ahtri tn 12, 10151 Tallinn, Harju maakond, Estonia

General: [email protected]

Privacy: [email protected] · [email protected]

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